Anti-Bribery and Anti-Corruption Policy
Purpose:
Infused SeedBall USA LLC (“ISB” or the “Company”) is committed to conducting our business in accordance with all applicable laws, rules and regulations and the highest ethical standards. This commitment is embodied in the Code of Business Conduct and Ethics.
The purpose of this Anti-Bribery and Anti-Corruption Policy is to reiterate Infused SeedBall USA LLC’s commitment to full compliance by the Company, its subsidiaries and affiliates, and its officers, directors, employees and agents with Canada’s Corruption of Foreign Public Officials Act (“CFPOA”), the U.S. Foreign Corrupt Practices Act (“FCPA”), and any local anti-bribery or anti-corruption laws that may be applicable. This Policy supplements the Code of Business Conduct and Ethics and all applicable laws and provides guidelines for compliance with the CFPOA, FCPA, and Company policies applicable to Infused SeedBall USA LLC operations world-wide.
For the purposes of this Policy, a “contractor”, “supplier” or “third party” is defined as an entity or individual who provides, and receives payment for, services or goods related to any aspect of a Infused SeedBall USA LLC operation, and includes consultants and subcontractors.
Scope:
This Policy is applicable to every employee of Infused SeedBall USA LLC, including senior executive and financial officers, and to members of the Infused SeedBall USA LLC Board of Directors. This Policy is intended to supplement all applicable laws, rules, and other corporate policies. It is not intended to supplant any local laws.
Definition:
Corruption is the misuse of public power for private profit, or the misuse of entrusted power for private gain. Bribery is the offer, promise, or payment of cash, gifts, or even excessive entertainment, or an inducement of any kind offered or given to a person in a position of trust to influence that person’s views or conduct or to obtain an improper advantage. Bribery and corruption can take many forms, including the provision or acceptance of:
Cash payments;
Phony jobs or “consulting” relationships;
Kickbacks;
Political contributions;
Charitable contributions;
Social benefits; or
Gifts, travel, hospitality, and reimbursement of expenses.
Policy Requirements:
Infused SeedBall USA LLC personnel and agents are strictly prohibited from offering, paying, promising, or authorizing:
any payment or other thing of value; to any person; directly or indirectly through or to a third party;
for the purpose of (i.e., in exchange for);
causing the person to act or fail to act in violation of a legal duty;
causing the person to abuse or misuse their position;
or securing an improper advantage, contract or concession;
for Infused SeedBall USA LLC or any other party.
Improper Payment Activity
To promote compliance with anti-corruption laws in Canada, the United States, and other applicable jurisdictions, no Infused SeedBall USA LLC personnel shall undertake any Improper Payment Activity in respect of a foreign official, a domestic official, or a person doing business in the private sector.
In addition, Infused SeedBall USA LLC’s books and records must correctly record both the amount and a written description of any transaction. Infused SeedBall USA LLC personnel must ensure that there is a reasonable relationship between the substance of a transaction and how it is described in the Company’s books and records.
It is contemplated that Infused SeedBall USA LLC will institute detailed procedures and standards related to training, due diligence, the recording of transactions, and other areas, to implement the terms of this Policy. In particular, Infused SeedBall USA LLC will institute standards and procedures for:
Sponsoring travel of government or government officials;
Direct and in-kind support for government or government officials;
Security support for public law enforcement;
Per diems for government officials;
Retaining third parties, including those who may interact with the government on Infused SeedBall USA LLC’s behalf;
Contracting with state-owned entities;
Meals, gifts, and entertainment for government officials; and
Donations and charitable contributions for government officials.
Audits:
Audit of Infused SeedBall USA LLC sites, operating units, and contractors may be conducted periodically to ensure that the requirements of this Policy and applicable procedures and guidelines are being met. Audits may be conducted internally by Infused SeedBall USA LLC, or externally by retained third parties. Audit documentation shall include performance improvement action plans.
Interaction with Other Corporate Policies
Other Infused SeedBall USA LLC policies impacted by, and which should be construed consistent with this Policy, include the Code of Business Conduct and Ethics.
Discipline:
Any employee who violates the terms of this Policy will be subject to disciplinary action. Any employee who has direct knowledge of potential violations of this Policy but fails to report such potential violations to Company management will be subject to disciplinary action. Any employee who misleads or hinders investigators inquiring into potential violations of this Policy will be subject to disciplinary action. In all cases, disciplinary action may include termination of employment. Any third party agent who violates the terms of this Policy, who knows of and fails to report to Infused SeedBall USA LLC management potential violations of this Policy, or who misleads investigators making inquiries into potential violations of this Policy, may have their contracts re-evaluated or terminated.
References:
For reference:
• The CFPOA can be found at: http://laws-lois.justice.gc.ca/eng/acts/c-45.2/index.html
• The FCPA can be found at: http://www.justice.gov/criminal/fraud/fcpa/
Contact Us
If you have any questions or concerns about this Anti-Bribery & Corruption Policy, please contact us at:
Infused SeedBall USA LLC: info@isbgroupofcompanies.com